Last updated on: 25 May 2018
Clever Age is engaged in a continuous effort to comply with the General Data Protection Regulation (GPDR) enacted on 27 April 2016. In line with the new regulation, Clever Age is enhancing its Personal Data Protection Policy to ensure that our users’ data are collected and used in a transparent, confidential and secure way.
PERSONAL DATA PROTECTION POLICY AS OF 25 MAY 2018
Our Personal Data Protection Policy lays out the way Clever Age handles the personal data of the visitors and users (hereinafter: “Users”) navigating through our website, www.clever-age.com (hereinafter: “Website”). The Personal Data Protection Policy is an integral part of the Website’s Terms and Conditions.
Clever Age pays constant attention to its Users’ data. As a result, we may modify, supplement or update the Personal Data Protection Policy. We invite you to regularly check the last existing version, available on our Website. Should major modifications be made to the Policy, we shall inform you thereof via email or through our services, so that you may look at these modifications prior to their coming into effect. By using our services posterior to the publication or emailing of a notice of modification to the Personal Data Protection Policy, you are agreeing to the updates.
WHICH PERSONAL DATA ARE BEING COLLECTED, AND TO WHAT END?
When you use our Website and/or when you subscribe to our newsletter or fill one of our contact forms, we collect and process personal data such as: your first and last names.
We also ask that you give us your email address, so that we may use it for the purpose of sending you information and notification emails as well as our newsletter.
We also collect the name of your company, your phone number, your IP address, and relevant information about why you contacted us (such as your needs in terms of DevOps or Responsive Web Design).
Clever Age uses real-time analysis and client identification services, such as Google Analytics or Woopra, which help collect your clickstream data. Such information is then used to analyze our Users’ points of interest and for statistical purposes.
When you share your contact details so that we may contact you, we may call you over the phone and ask for further information regarding your request. Such data can then be saved, read, used, supplemented, extracted and communicated in order to best serve your needs.
In the context of satisfaction surveys, we may employ a client satisfaction measurement tool (cookiebot.com). Through this tool, you will be asked to give a written opinion on Clever Age’s services. Additional information may be gathered during the business exchanges between Clever Age and a client, including: position within the company, LinkedIn account, preferred language for communication.
To sum it up, we collect the information you provide, particularly when:
- you navigate through our website;
- you fill in a contact form;
- you fill in an application form for one of our job offers;
- you contact our sales department;
- you land on our Website after having clicked on a link in one of our emails;
- you subscribe to one of our events.
ARE YOUR PERSONAL DATA SHARED WITH THIRD PARTIES?
The personal data collected on our website shall be used by Clever Age, and may be shared with our subcontractors to allow them to deliver our services.
Clever Age shall not in any case sell or rent your personal data to third parties for the purpose of marketing. We also work in close collaboration with third companies which may have access to your personal data, including:
- when you explicitly request it (i.e. when you apply through LinkedIn);
- when we solicit search engines and analytical solutions providers to enhance and optimize our Website;
- when we are legally obliged to do so, or when we believe in good faith that it is necessary (i) to respond to a claim made against Clever Age, (ii) to comply with a judicial request, (iii) to perform any contract with our Users, such as the Terms and Conditions and this confidentiality policy, (iv) in the event of an emergency where an individual’s health or physical integrity is at stake, (v) in the case of surveys and investigations, or (vi) to protect the rights, the goods and the security of Clever Age, of its members and more generally of any third party.
- Furthermore, Clever Age shall not disclose your personal data to third parties, unless (1) you (or your account manager acting on your behalf) shall express such a wish or authorize their disclosure; (2) disclosure is necessary to process transactions or provide services you requested; (3) Clever Age is forced to do so by a government authority or regulatory body, in the case of a formal judicial request, a subpoena, or any other similar judicial or government request, or in order to establish or support a judicial request; or (4) the third party is acting as an agent or subcontractor performing Clever Age’s services.
Should Clever Age, its assets or part of its assets be acquired by a third party, the data we hold would, if applicable, be transferred to the new owner. We may aggregate data about you that we receive from or send to our business partners, including all or part of your personal data and the information gathered through cookies. This aggregated information shall only be used for the purposes described above. Upon simple request, we shall provide you with the list of countries where we store your data and through which your data are occasionally sent. We transfer and store your data not only in the European Union, but also in the United States.
HOW DO WE PROTECT YOUR PERSONAL DATA?
Clever Age implements the organizational and technological security measures generally recognized to ensure that the personal data collected are not being lost, misused, read, modified or disclosed by unauthorized third parties, unless communicating these data is required by the existing legislation, including upon request from a judicial or police authority, or any other body duly authorized by law.
HOW LONG ARE CLEVER AGE’S USERS PERSONAL DATA HELD FOR?
Personal data imparted by the Users of the Website www.clever-age.com shall be deleted following a set time period for each process. In any case, your data shall not be held over thirty-six (36) months.
We only hold your data for the time fit for purpose, in compliance with the legal requirements.
WHAT ARE YOUR RIGHTS?
In accordance with the existing regulation, the Users of the Website have the following rights:
- right to access and rectify;
- right to update and supplement the Users’ data;
- right to block or delete the Users’ personal data when they are inaccurate, incomplete, equivocal, obsolete, or when their collection, utilization, communication or holding is forbidden;
- right to withdraw consent at any given moment;
- right to limit the processing of the Users’ data;
- right to object to the processing of personal data;
- right to portability of the data provided by the Users, when these data are being automatically processed based on their consent or a contract.
If you wish to know how Clever Age uses such personal data, to rectify them or to object to their processing, please send an email to firstname.lastname@example.org or a letter to Data Protection Officer Clever Age, 34 rue de Saint-Pétersbourg, 75008 Paris, France.
Finally, Clever Age Users may file a complaint with supervisory authorities, particularly the CNIL (https://www.cnil.fr/plaintes).
Your requests shall be handled within thirty (30) days. We ask that you join a copy of your ID to your request so that Clever Age may verify your identity.
CONTACTING OUR DATA PROTECTION OFFICER
If you have any question or complaint or if you wish to share recommendations or comments to improve Clever Age’s Personal Data Protection Policy, please send an email to email@example.com or a letter to Data Protection Officer Clever Age, 34 rue de Saint-Pétersbourg, 75008 Paris, France.